Parrish et al v. National Football League Players Incorporated

Filing 536

Letter Brief re Motion to Strike Testimony filed byBernard Paul Parrish, Walter Roberts, III, Herbert Anthony Adderley. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D)(Katz, Ronald) (Filed on 11/3/2008)

Exhibit C to
Plaintiffs' Letter Brief Striking Statements by Defendants' Witnesses

Stephen Saxon, Esq.

October 1, 2008 Page 1

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UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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BERNARD PAUL PARRISH, HERBERT ANTHONY ADDERLEY WALTER ROBERTS, III,

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Vs. 6

Plaintiffs, CASE NO.. C 07 00943

NATIONAL FOOTBALL LEAGUE PLAYERS ASSOCIATION and

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NATIONAL FOOTBALL LEAGUE PLAYERS INCORPORATED d/b/a

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PLAYERS INC, Defendants.

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---- -- -------------------DEPOSITION OF STEPHEN SAXON, ESQ.

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October 1, 2008 9:00 a.m. 700 12th Street, N.W. Washington, D.C.

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19 Linda Ann Crockett, a Notary Public

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Stephen Saxon, Esq.

October 1, 2008 Page 16

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BY MR. LeCLAIR:

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Q.

If you look at the first page,

Mr. Saxon, there's questioning here about the independent assessment of the $8 million reallocation that occurred in 2006. And we

will talk about it in detail. I'm not meaning to go into it right now. I'm simply asking whether Mr. Berthelsen's testimony that you gave advice about that subject is correct? MR. FEHER: can answer. A. Q. What was your question? Was Mr. Berthelsen.correct that you Objection to form. You

did provide legal advice about the $8 million reallocation that occurred in 2006? A. That's correct.

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Q.

If you look at Page 3 of Exhibit 3 to

your deposition? A. Q. Exhibit 3. Page 3. There's a statement at the

top that, quote, Steve Saxon, who I mentioned previously, appears at every player rep
meeting, and I'm sure he would have talked about it, most certainly. Closed quote. Is it accurate that you appeared at every player

Stephen Saxon, Esq.

October 1, 2008

Page 17

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rep meeting? A. I've been at every player rep meeting

since about 1993 or so.
Q.

And is that Board of Player

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Representatives?
A. Q. A. Q. That's correct.
That runs the NFLPA?

That's correct. What is your role at such meetings? MR. FEHER: Objection. You can

answer.

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A. Q.

I'm outside tax counsel. Are you responsible in any way for

keeping minutes of such meetings? A. Q.
A.

No. Are minutes kept of such meetings?
Yes.

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Q.
A.

Who keeps them?
Richard Berthelsen.

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Q.

Are agendas prepared for such

meetings?
A. My understanding is that, yes, there

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are.
Q. And are presentations made at such

meetings?

Stephen Saxon, Esq.

October 1, 2008 Page 172

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REPORTER'S CERTIFICATION STATE OF MARYLAND COUNTY OF BALTIMORE

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I,

Linda A. Crockett, a Notary Public

of the State of Maryland, do hereby certify
that the within named, STEPHEN SAXON, was

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deposed at the time and place herein set out, and after having been duly sworn by me, was interrogated by counsel.
I further certify that the examination

was recorded stenographically by me, and this transcript is a true record of the proceedings. I further certify that the

stipulations made herein were entered into by counsel in my presence. I further certify that Iam not of

counsel to any of the parties, nor an employee of counsel, nor related to any of the parties, nor in any way interested in the outcome of this action.

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As witness my hand and notarial seal this 3rd day of October, 2008. My commission expires: December 1, 2008

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